Sediment and Surface Water Investigation Work Plan for the ... · The sediment sampling strategy...

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Submitted to BP Products North America, Inc. Neodesha, Kansas Submitted by AECOM 1000 North Sterling Ave Sugar Creek, Missouri February 2016 Sediment and Surface Water Investigation Work Plan for the Former Refinery at Neodesha, Kansas

Transcript of Sediment and Surface Water Investigation Work Plan for the ... · The sediment sampling strategy...

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Submitted to BP Products North America, Inc. Neodesha, Kansas

Submitted by AECOM 1000 North Sterling Ave Sugar Creek, Missouri February 2016

Sediment and Surface Water Investigation Work Plan for the Former Refinery at Neodesha, Kansas

rpierson
Received
rpierson
Text Box
MAR 2 2016
rpierson
Approved
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Table of Contents 1 Introduction..................................................................................................................................................................1-1

1.1 Background ...........................................................................................................................................................1-1 1.2 Rationale ...............................................................................................................................................................1-1 1.3 Scope of Work .......................................................................................................................................................1-2

2 Investigation Methods .................................................................................................................................................2-1

2.1 Health and Safety ..................................................................................................................................................2-1 2.2 Property Ownership and Access.............................................................................................................................2-1 2.3 Mobilization ...........................................................................................................................................................2-1 2.4 Sampling Methodology ...........................................................................................................................................2-1

2.4.1 Sample Location Selection ............................................................................................................................2-2 2.4.2 Sampling Procedures ....................................................................................................................................2-2

2.4.2.1.1 Surface Water ........................................................................................................................... 2-2 2.4.2.1.2 Sediment .................................................................................................................................. 2-2

2.4.3 Analytical Methods ........................................................................................................................................2-3

2.5 Quality Assurance/Quality Control ..........................................................................................................................2-3 2.6 Decontamination and Waste Management ..............................................................................................................2-4 2.7 Surveying ..............................................................................................................................................................2-4

3 Sediment and Surface Water Investigation .................................................................................................................3-1 3.1 Fall River: Upstream ..............................................................................................................................................3-1 3.2 Fall River: Potential Discharge Areas......................................................................................................................3-1 3.3 Fall River: Downstream Area ..................................................................................................................................3-2 3.4 Verdigris River .......................................................................................................................................................3-2 3.5 Visual Seep Assessment........................................................................................................................................3-2

4 Schedule ......................................................................................................................................................................4-1 5 Data Evaluation and Reporting ....................................................................................................................................5-1 6 References ...................................................................................................................................................................6-1

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List of Appendices

Appendix A Standard Operating Procedures

List of Tables

Table 1 Analytical Parameters Table 2 Proposed Sediment and Surface Water Sampling Locations

List of Figures

Figure 1 Site Location Map Figure 2 Sampling Locations and Ownership Map

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1.1 Background This Work Plan describes the proposed supplemental sediment and surface water investigation that BP will be implementing in 2016. Previously, BP has completed environmental assessments of conditions associated with the Former Refinery (Site), including surface water sampling in the Fall and Verdigris Rivers. These assessments document groundwater contamination beneath the Former Refinery Site, as well as in an off-site area east of the Former Refinery property, and potential remedies to address the contamination through a Corrective Action Study (CAS) (BP, 2005). The environmental assessments conducted to date have provided information on soil, groundwater, surface water, sediment and air quality; however, BP has previously agreed (Atlantic Richfield, 2004) to conduct additional sediment sampling as part of the Corrective Action Plan (CAP) phase. The Kansas Department of Health and Environment (KDHE) has also requested (KDHE, 2008a) additional sampling of sediment to be incorporated into the CAS. This document is an update to the original work plan submitted to KDHE in 2008 (BP, 2008), which was not implemented due to access issues associated with a lawsuit between BP and the City of Neodesha. This work plan is designed to characterize the Fall River sediment in areas where there is surface water and groundwater discharge into the Fall River from the area of the Former Refinery.

1.2 Rationale Sample locations have been selected to characterize areas where groundwater from the Former Refinery has the potential to discharge to the Fall River. In addition, sample locations have been selected where storm water from the area of the Former Refinery discharges to the Fall River through drainage ditches. Groundwater discharging to the river may have the potential to impact sediment in the groundwater/surface water hypothetic zone, as sediment with high organic content typically has a high affinity for adsorption of organic contaminants. Fine-grained sediment impacted by such contaminants may further have been resuspended and redeposited in depositional areas farther downstream. Therefore, the sediment sampling program focuses on:

(a) Collection of fine-grained sediment (and co-located surface water) samples from selected downstream depositional locations of the hypothesized routes of entry to determine if Site-related impacts exist. To make such a determination, it is necessary to also collect similar samples upstream of the supposed groundwater entry point to determine if observed impacts are associated with upstream reference conditions or with groundwater discharges from the Site.

(b) Collection of sediment (and co-located surface water) samples near the mouth of a storm water drain west of the Site (downstream of the former Oil Separator Pond Site).

(c) Collection of one sediment sample near the mouth of a storm water drain south of the Site (south of the former Settling Basins).

The evaluation proposed in this Work Plan will consider current conditions, and will be used to help evaluate if potential risk to human health or the environment exists. As a result, the evaluation focuses on the surface sediment layer, which is the biologically active zone (BAZ) and which may experience human contact and be susceptible to resuspension. Limited surface water sampling has occurred in the past as part of an ongoing semiannual monitoring program. Four locations have been sampled in the Fall River with two locations being upstream of the Former Refinery (Fall/Up and Fall/Park) and two locations near the suspected discharge area (Fall/Intake and Fall/75). In addition, surface water samples have been collected from two locations in the Verdigris River (Verdigris/Up and Verdigris/75). However, to

1 Introduction

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address the specific concerns related to potential discharge of contaminants via groundwater, these locations may not be adequate. This sampling plan will modify the sampling locations to ensure that the objectives are met. In addition to sediment sampling, co-located surface water samples will be collected and compared to Kansas Surface Water Quality Standards. The issues related to additional sediment and surface water sampling were outlined in comment #9 in the letter to BP from C. Carey of KDHE on April 14, 2008 (KDHE, 2008a), with subsequent requests outlined in a letter to BP from C. Carey of KDHE on September 8, 2008 (KDHE, 2008b) . This sampling approach serves as formal documentation of that proposed scope of work to address these comments.

1.3 Scope of Work In response to KDHE comments on the work plan submitted in 2008 (KDHE, 2008a and KDHE, 2008b), supplemental sediment and surface water samples will be collected from the Fall River as described in the following sections. A total of 17 sediment and co-located surface water sampling locations will be selected and sampled as shown in Figure 1. These locations address the additional sampling locations requested by KDHE and agreed upon by BP, which include the two Verdigris River locations and a location from the former oil separator pond area (near Water Plant Road). These locations are defined on Figure 1.

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2 Investigation Methods

This section presents the field sampling and laboratory analytical methods. It includes descriptions of all relevant field tasks including sampling equipment and procedures, laboratory analytical methods, quality assurance and quality control, equipment decontamination, and surveying.

2.1 Health and Safety A Site-Specific Health and Safety Plan (HASP) has been developed as a separate document to ensure the safety of those working at the Site, as well as the public, during fieldwork activities. In addition, a separate Task Risk Assessment (TRA) will be developed for sampling sediments and surface water from the river. An initial health and safety kickoff meeting will be held prior to initiating fieldwork activities to discuss information contained in the HASP and TRA. In addition, all employees and contractors will undergo a Site orientation to discuss specific AECOM and BP safety policies, as well as complete forms to identify individual risks of work activities. Daily safety meetings will be held at the beginning of each workday to discuss daily project objectives and important safety issues. Because the sampling program will involve working on or adjacent to water bodies, additional health and safety considerations required by both AECOM and BP will be implemented. All personnel involved with sampling will undergo necessary orientation to meet BP on-water and boating safety requirements in accordance with Standard Operation Procedure (SOP) 419.

2.2 Property Ownership and Access The sampling locations will require access via a small boat, as sampling from the river banks would be difficult due to physical constraints and difficulty in evaluating specific sample locations. Boat access to the Fall River will occur at the existing boat ramp on the Fall River for locations upstream of the Highway 75. Locations below the overflow dam located downstream of the Highway 75 dam may require seeking out suitable boat or canoe access points, as the dam is not navigable. With the exception of the three public rivers, the Missouri River, the Kansas River, and the Arkansas River, streams and rivers in the state of Kansas are privately owned and permission from the adjacent landowners to access and use the Fall River will be required before sampling can occur. The landowners of the adjacent properties are identified in Figure 1 and will be contacted once this Work Plan is approved. Some sampling locations may be easier to access from bridges spanning the river. These locations will be evaluated before sampling occurs. There are no known access issues anticipated for sampling from bridges. Appropriate safety precautions for traffic safety will be implemented as necessary to ensure health and safety.

2.3 Mobilization The mobilization point and field operations base for the investigation is the BP building located at 1100 North 12th Street in Neodesha, Kansas. A staging area for containerized investigation residuals (e.g., trash, decontamination fluids) will be established near the remediation building as well. The sampling team will mobilize to the sampling locations using a small boat or possibly a canoe if access otherwise is difficult. The boat will be launched in the Fall River at the public boat ramp and other predetermined location for downstream locations. The team will then travel by boat to the selected sample locations.

2.4 Sampling Methodology This section presents procedures for site selection and sediment and surface water sampling to be conducted at the Site. SOPs referenced in the text are provided in Appendix A. Where the text of the Work Plan and SOPs differ, the Work Plan takes precedence.

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2.4.1 Sample Location Selection

The overall strategy and locations for sample collection are described in Section 3. In this section, specific considerations for selection of specific sample collection locations within the overall sample location are described. The sediment sampling strategy focuses on sampling sediment (and overlying water) at areas where contaminants entrained in mobile sediment particles may have been deposited and be subject to resuspension or exposure. It is therefore not appropriate to pre-define exact sample locations for sediment sampling, but to define general locations for sampling within which sediment of suitable characteristics is then located and sampled. Because contaminants have a higher affinity for fine-grained sediment (and especially the organic carbon of the sediment), meeting the objective of locating transported contaminants is to seek to sample fines, i.e. sediments with at least 15% content of silt and clay in depositional zones. Depositional zones form in areas such as eddies, embayments, trailing point bars or inside meander banks. If debris or gravel inclusions are present in the sediment sample, they will be removed from the sample. The procedure to select a sample location is as follows:

• Locate the selected general sample location.

• Locate the nearest area where hydrological conditions would suggest a depositional zone (embayment, eddies, pools, trailing point bar, or inside meander bank). Collect sample if visually confirmed that the sediment appears to meet the 15% fines minimum). If the area is submerged, it may be necessary to collect test samples to confirm that conditions are met.

• If conditions are not met at a location, step-out from the location until a suitable location is found. In some areas repeated attempts may be necessary due to gravel, hardpan or swift current.

• It is important to ensure that sediment samples, to the extent feasible, be as similar in physical characteristics as possible to allow comparison between samples. To this end all samples will be analyzed for particle size distribution and organic carbon content.

2.4.2 Sampling Procedures

2.4.2.1.1 Surface Water Surface water sampling at a location always precedes sediment sampling to avoid introducing resuspended sediment. In addition, sampling will be performed downstream to upstream to avoid cross contamination of the samples with resuspended sediment from previous sampling locations. Surface water sampling is conducted by manually introducing an inverted glass sampling container into the water, carefully avoiding introducing any surface floatables or films to the container, to approximately 1-2 feet depth (at least elbow depth) and then inverting and filling the bottle. The sample is raised and transferred to the appropriate sample containers or field filtering device. Field parameters, to include dissolved oxygen (DO), pH, Specific Conductivity, and Oxidation-Reduction Potential will be measured using an appropriate field instrument and recorded in the surface water sample documentation.

2.4.2.1.2 Sediment Sediment sampling will be conducted using a Petit Ponar or Ekman sampling device. These sampling devices use a clamshell scoop triggered by the operator to collect a quantitative grab sample of surface sediment, reaching approximately to a depth of 4 inches. These sampling devices work best in soft sediment material (clay, silt and sand) but are less efficient if there is debris or gravel in the sediment. As samples are intended to be collected from depositional, fine-grained material, if debris or gravel is encountered, sampling will be stepped-out until suitable conditions are found. It is anticipated that several grabs will be necessary to collect sufficient sample for complete analysis.

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The overall sediment sampling strategy is to collect and analyze fine-grained, depositional samples from the top 10 centimeters of sediment for characterization of sediment contamination. Based on the steep-banked and deep characteristics of the Fall River, samples will be collected from the submerged river bed and not from exposed flats or banks. Sufficient sediment grabs will be accumulated in a stainless steel bowl for all analytical needs. Larger debris and gravel will be removed by hand. Samples for volatile organic compound (VOC) analysis will be collected representatively from the stainless steel bowl prior to homogenizing to minimize loss of volatiles. Following VOC sampling, samples will be homogenized and distributed to suitable containers. The sampling documentation will document sample numbers, type and structure of sediment, and other relevant Site conditions.

2.4.3 Analytical Methods

To characterize sediment and surface water, compounds specific to refinery related products will be analyzed. Samples will be analyzed for methods that encompass all of the compounds included on the United States Environmental Protection Agency (USEPA) Region 5 Skinner List (USEPA, 1997). These methods also include additional compounds not included on the Skinner List. For polyaromatic hydrocarbons (PAHs), all 16 Priority Pollutant PAHs will be reported, in order to allow the calculation of total PAH values. In addition, all inorganics included on the Skinner List will be analyzed, including all Resource Conservation and Recovery Act metals. More specifically, analyses of sediment and surface water samples will include the following constituents and methods:

• VOCs including benzene, toluene, ethylbenzene, and xylenes (BTEX), hydrocarbons, solvents, and oxygenates by USEPA Method 8260B, collected via SW-846 Method 5035 (USEPA, 1996a).

• Semivolatile organic compounds and PAHs by USEPA Method 8270C. To achieve the detection limits necessary to evaluate sediment, PAHs will be analyzed using USEPA Method 8270CSIM.

• Total petroleum hydrocarbons by USEPA Methods 8015M OA-1 and OA-2.

• Skinner’s List inorganics by USEPA Method 6010B. For surface water samples, both dissolved (filtered) and total metals will be analyzed. Sample filtering will be conducted in the field in accordance with AECOM SOP 7131.

• pH by Method 150.1.

• Total organic carbon (sediment only) by Standard Methods Method SM 5310C.

• Particle Size Distribution (sediment only) by American Society for Testing and Materials (ASTM) method D422 for clay material and ASTM Method D1140 for sandy material.

Table 1 presents a complete list of analytical parameters and the reporting limits to be used, which are expected to meet relevant screening levels.

2.5 Quality Assurance/Quality Control To collect data of sufficient quality for use in characterization and risk assessment, quality assurance/quality control (QA/QC) procedures are required. Sample collection, storage, and shipment will be conducted following proper chain-of-custody protocol in accordance with the Site Quality Assurance Project Plan (QAPP) (ENSR 2008). All analytical data generated as part of the supplemental sediment and surface water assessment will be validated. Data validation will be performed in accordance with the methods defined by the National Functional Guidelines for Organic Data Review (USEPA, 1991) and summarized in the QAPP. One duplicate sample will be collected every 20 samples. As the total number of samples is anticipated to be 17 samples, one duplicate surface water, and one duplicate sediment sample will be collected. In addition, trip blanks, a sediment field/equipment rinsate blank, and sufficient sample to allow the laboratory to conduct a matrix spike and spike duplicate will be collected.

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2.6 Decontamination and Waste Management All sampling equipment will be decontaminated prior to initial use and before each sample collection. Decontamination solution for this project will consist of an Alconox® detergent solution followed by a thorough distilled water rinse. All decontamination materials and fluids will be containerized. During fieldwork, steps will be taken to minimize the volume of decontamination materials and fluids generated. Where practical, disposable sampling equipment and personal protective equipment will be decontaminated and handled as routine solid waste. Solid waste will be containerized in trash bags and routed for solid waste disposal. Limited amounts of fluids are anticipated, which will be collected in a covered bucket. Decontamination fluids will be treated at BP’s Wastewater Treatment Plant. In general, based on existing conditions, it is not anticipated that heavily contaminated areas will be encountered in the Fall River.

2.7 Surveying The locations of sediment and surface water samples will not be surveyed; however, their locations will be recorded utilizing a hand-held global positioning system (GPS) unit. The GPS information will be used for generating maps and graphics during data evaluation and reporting.

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3 Sediment and Surface Water Investigation

This section presents the specific sediment and surface water investigation plan. Figure 1 shows the locations and Table 2 presents sample specific rationales. Surface (0 to 4 inches) sediment samples will be collected during the investigation, as well as co-located surface water samples. Sampling will be conducted during a period of low-flow or base flow conditions, as requested by KDHE. Figure 1 shows the proposed approximate sample locations. Final locations will be determined in the field as described in Section 2.4.1. Note that the proposed sampling program expands on the request from KDHE to sample the six established locations in addition to two or more locations immediately downgradient of the former Oil Separator Pond Site. Specifically:

• BP proposes to expand the “upstream” sampling program in the Fall River from two to five locations.

• BP proposes to expand on the “groundwater discharge area” sampling program in the Fall River from one established location to four locations.

• BP proposes to expand the “downstream” sampling from one location to five locations. These locations include the additional two samples requested by KDHE.

• BP proposes to sample sediment at the two Verdigris River locations. Surface water from the Verdigris River locations is currently sampled independently as part of semi-annual monitoring, however, will be collected as well during this work if outside of the semi-annual schedule.

• BP proposes to sample sediment and surface water at one location from the former Oil Separator Pond Site, located near Water Plant Road.

Figure 1 depicts proposed locations of sediment and co-located surface water samples and sampling areas in the Fall River. Table 2 summarizes each of the proposed sample locations and provides a rationale for the selection of each location. The field personnel may modify sample locations as described in Section 2.4.1 to meet the data objectives. The following sections provide a description of each area and the number of proposed samples.

3.1 Fall River: Upstream As there are multiple other potential sources affecting Fall River surface water and sediment quality, it is important to acquire a representative set of samples from areas upstream of, and thus unaffected by, any discharges related to the Site. Previous aquatic monitoring programs have established two locations for upstream water collection: the “Fall/Up” location at the Huser Bridge a few miles upstream, and the “Fall/Park” location at the public park approximately 1500 feet upstream of the outfall of the creek and ditch that formerly drained the Former Oil Separator Pond Site. As sampling will be conducted from a boat, the sampling will be conducted in mid-stream and not from the shore or bridges as in previous sampling. Therefore these locations will not be specifically targeted. A total of five samples will be collected in the upstream reach of the Fall River, from approximately the location of the “Fall/Park” location, and then approximately every 2000 feet upstream to the “Fall/Up” location. These samples will be collected subsequent to collection of downstream samples in a downstream to upstream sampling order to (a) avoid contamination of downstream locations as a result of sampling activities, and (b) allow location of sediment sampling locations of similar physical characteristics as observed in the study area to allow sample comparisons.

3.2 Fall River: Potential Discharge Areas Previous studies have determined that the former Oil Separator Pond discharges to a drainage ditch/creek that also collects runoff from the railroad line and other upstream areas and ultimately reaches the Fall River. Sampling has

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previously been conducted in this ditch/creek. These samples are intended to identify any sources of contaminants to the river. In addition, KDHE notes in its request that the contaminant plume may be closer to the Fall River in the area just north of the Highway 75 bridge than previously established. Additional sampling in this area has therefore been requested by the agency. Currently, one established surface water sample location is in the area(Fall/Intake) of the Neodesha water intake. To evaluate the potential for discharges from the former Oil Separator Pond ditch and the groundwater plume, a total of five co-located surface water and sediment samples are proposed.

• Two samples to be collected from the location of the mouth of the ditch draining the Former Oil Separator Pond Site. One of these samples is to be collected at the mouth of the ditch. The second sample is to be collected in the river immediately down-gradient of the mouth of the ditch, at the first depositional location with sufficient fines available to meet the sampling objectives.

• One sample is to be collected immediately off-shore to the point in the riverbank where the groundwater from the Site makes its closest approach to the river. The sample is to be collected in submerged sediment on or near the bank.

• One sample is to be collected at the “Fall/Intake” location. The sediment sample is to be collected in any suitable sediment adjacent to the intake location.

• One sample is to be collected from the former Oil Separator Pond Site, located near Water Plant Road. The sample is to be collected from the ponded area, just west of Water Plant Road.

3.3 Fall River: Downstream Area The samples collected in the suspected discharge areas (ditch and groundwater plume) are intended as identification samples to evaluate if contaminated water or sediment may be entering the Fall River A total of five sediment and surface water samples are proposed to be collected from the downstream reach of the river. These samples are to be collected from depositional zones with sufficient fine-grained sediment to meet the objectives, starting at the established “Fall/75” location at the highway bridge. The sample farthest downstream will be located just downstream of the outlet of a storm water ditch that drains portions of the Former Refinery. Per KDHE request, this sample will serve as an indicator of potential discharges from this storm water discharge.

3.4 Verdigris River

Samples will be collected from depositional zones with sufficient fine-grained sediment to meet the objectives, starting at the established “Verdigris/UP” and the “Verdigris/75” locations. These samples are intended to establish baseline conditions should the Verdigris River ever become impacted as a result of historical or current operations related to the Former Refinery or associated remediation efforts.

3.5 Visual Seep Assessment

Per KDHE request in Comment #9 of KDHE (2008a), a visual seep assessment will be conducted along the shoreline between the mouth of the ditch to the highway bridge, to be conducted in association with low-flow or base flow conditions. The objective of the seep assessment is to determine if any seepage of potentially contaminated groundwater may be occurring in the stretch of riverbank closest to the Former Refinery Site. If such seepage is observed, location, apparent flow, and other characteristics of the seepage will be recorded. In particular, the presence

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of sheens, odors, or other indicators of potential contaminant releases will be noted. It should be noted that potential contributions from non-site related sources also will need to be considered. In addition, should any seeps be identified during the assessment, and coincident with sheens, odors, or other indicators of potential contaminant releases, BP will collect seep samples from those locations, and submit for analysis the analytical methods defined in Section 2.4.3 of this Work Plan.

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4 Schedule

A schedule to implement the Sediment and Surface Water Investigation Work Plan has been developed and is as follows:

• Field work is planned to start following KDHE review and approval of this Work Plan and access to the sampling locations have been obtained. In addition, the field work will be performed with the rivers at base flow or low flow conditions. Flooding or heavy precipitation events will alter the schedule and will delay sampling until the river water levels have stabilized. BP will notify the KDHE of the dates.

• The sediment and surface water results will be presented in the Supplemental Investigation Report, which is planned to be generated within two months following receipt of analytical data.

If there is any schedule change, BP will coordinate with KDHE on the revised sampling schedule.

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5 Data Evaluation and Reporting

Data generated during the Sediment and Surface Water Investigation will be evaluated and included in a Supplemental Investigation Report. Data evaluation activities include tabulation and evaluation of field data and quantitative analytical data, and screening of the data against appropriate screening levels. The Sediment and Surface Water Investigation portion of the Supplemental Investigation Report will include:

• Summary of all field investigation activities;

• Summary of any deviations from the Work Plan;

• Maps of sample locations;

• Figures and tables presenting characterization of data, including screening against appropriate screening levels

• Raw analytical data, QA/QC summary, and validation information;

• Copies of all field notes and forms; and

• Evaluation of sediment and surface water data.

Screening levels that are Applicable or Relevant and Appropriate (ARAR) for sediment and surface water will be used to evaluate the data. If exceedances are noted, consultation with KDHE will determine the appropriate path forward. For surface water, Kansas Water Quality Criteria (WQC) per K.A.R. 28-16-28e(d) will be applied as screening levels. In the absence of a Kansas WQC for a parameter, alternate sources of screening levels will be consulted, in the following hierarchy: U.S. National Recommended Water Quality Criteria (USEPA, 2013), U.S. EPA Ecotox Thresholds (ET) (USEPA, 1996b), U.S.EPA Region 5 Ecological Screening Levels (ESLs) (USEPA, 2003), Tier 2 ambient water quality criteria (USEPA, 1996c), or other sources. For sediment, in accordance with KDHE’s sediment policy, BER-ARS-045, the McDonald Consensus Based Sediment Quality Guidelines (McDonald et al. 2000), will be used. Data will be compared to both Threshold Effect Concentrations (TECs) and Probable Effect Concentrations (PECs). In the absence of consensus sediment quality guidelines, other sources will be consulted, including U.S.EPA ETs (USEPA, 1996b), Region 5 ESLs (USEPA, 2003) and other sources. Applicable screening levels will be presented in the Supplemental Investigation Report. Following completion of the Supplemental Investigation Report, the report will be submitted to the KDHE.

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6 References

Atlantic Richfield, 2004. Response to Comments on the Corrective Action Study for the Neodesha Former Refinery, Neodesha, Kansas, December 7, 2004.

BP, 2005. Corrective Action Study, Revision 1. Former Amoco Refinery, Neodesha, Kansas. February 7, 2005. BP, 2008. Revised Work Plan for the Installation of 31 Monitoring Wells and Replacement of 1 Pumping Well at the Former Amoco Refinery located in Neodesha, Kansas. May 28, 2008. ENSR, 2008. Quality Assurance Project Plan, Amoco Neodesha Former Refinery, Neodesha, Kansas, September

2008. KDHE, 2008a. Comments on the Work Plan for the Installation of 31 Monitoring Wells and Replacement

of 1 Pumping Well at the Former Amoco Refinery located in Neodesha, Kansas. April 14, 2008. KDHE, 2008b. Fall 2008 Investigation Work Plans, Neodesha Refinery Site, Neodesha, Kansas. September 8, 2008. MacDonald et al., 2000. "Development and Evaluation of Consensus-Based Sediment Quality Guidelines for Freshwater Ecosystems". Archives of Environmental Contamination and Toxicology. 39:20-31. USEPA, 1991. National Functional Guidelines for Organic Data Review. United States Environmental Protection Agency

Contract Laboratory Program. Revised, June 1991. USEPA, 1996a. Method 5035: Closed-System Purge-And-Trap and Extraction for Volatile Organics in Soil and Waste

Samples. December, 1996. http://www.epa.gov/epaoswer/hazwaste/test/pdfs/5035.pdf USEPA, 1996b. Ecotox Thresholds. United States Environmental Protection Agency. Office of Solid Waste and Emergeny Response. Intermittent Bulletin, Vol 3(2). EPA540/F-95/038. January. USEPA, 1996c. Ecotox Thresholds. United States Environmental Protection Agency. Office of Solid Waste and Emergency Response. Intermittent Bulletin, Vol 3(2). EPA540/F-95/038. January. USEPA, 1997. Region 5 Waste Management Branch “Skinner List” Constituents of Concern for Wastes from Petroleum

Processes. Attachment 1. Internet reference may be found at: http://www.epa.gov/reg5rcra/ca/r5skin.pdf USEPA, 2003. Region 5 RCRA Ecological Screening Levels. August 22, 2003. USEPA, 2013. National Recommended Water Quality Criteria. Office of Water, Office of Science and Technology. Internet reference may be found at: http://www.epa.gov/wqc/national-recommended-water-quality-criteria

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Y:\Reports\Neodesha\SSWI_WP\SSWI Final\Sediment and

Surface Water Investigation Work Plan 20160229.docx

Appendix A Standard Operating Procedures (SOPs)

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Americas

Boat and Vessel Operations S3NA-419-PR1

1.0 Purpose and Scope 1.1 Establishes the procedure for AECOM employees who perform work on boats and vessels.

1.2 This procedure applies to all AECOM Americas-based employees and operations.

2.0 Terms and Definitions Refer to S3NA-419-WI1 Nautical Terminology for more definitions.

2.1 Small Boat – A boat less than 18 feet in length including canoes, kayaks, rafts, and dinghys with an outboard motor.

2.2 Mid-size Boat – A boat greater than 18 feet but less than 26 feet in length, including single and pontoon-style hulls, barges, or other platforms.

2.3 Large Vessel – A boat or vessel larger than 26 feet in length.

2.4 Boat or Vessel Operator – Person responsible for the overall safe operation of the boat/vessel.

3.0 References 3.1 S3NA-003-PR1 SH&E Training

3.2 S3NA-208-PR1 Personal Protective Equipment

3.3 S3NA-209-PR1 Hazard Assessment and Planning

3.4 S3NA-301-PR1 Confined Spaces

4.0 Procedure 4.1 Roles and Responsibilities

4.1.1 Region Safety, Health and Environment (SH&E) Manager / SH&E Department

Provide training and technical guidance to operation, including the following:

• Approve safety plans. • Approve personnel assigned safety duties.

4.1.2 Project Manager

Responsible for the overall success of a project and the performance of employees engaged in project activities. The Project Manager identifies and implements all appropriate SH&E procedures. Additional responsibilities include the following:

• Confirm that subcontractors selected to support project operations have been approved by the AECOM Region SH&E Manager.

• Select an appropriate boat/vessel for the planned work activities. • Obtain approval from the AECOM Region SH&E Manager for the operation of any vessel in

offshore, ports or harbors, navigation channels, or waterways handling commercial ship traffic. • Develop and submit a Safe Work Plan, Task Hazard Analysis, Float Plan and other SH&E

Planning Documents for review and approval by the Region SH&E Manager. • Allocate appropriate resources, including emergency and safety equipment, to complete the

project as planned. • Designate a Marine Safety Officer to implement and maintain safe work practices and

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procedures. Marine Safety Officers are responsible for the following: o Implement and monitoring safe work practices specified by this procedure and supporting

SH&E documentation. o Conduct marine safety briefings and inspections as needed. o Conduct field verification of the competency of boat/vessel operators and field staff.

4.1.3 Boat/Vessel Operator

• Maintain current boating/vessel licenses as required by local, State, Provincial, and Federal regulations and standards.

• Operate boats/vessels in accordance with this SOP and as required by local, State, Provincial, and Federal regulations and standards.

4.1.4 Marine Safety Officer

• Shall be designated by the Project Manager and approved by the Region SHE Manager. • Have experience in boat and vessel operations similar to those planned for the operation.

4.1.5 Field Staff

• Comply with the safe work practices specified in this procedure and all other applicable AECOM SH&E policies.

• Verify that they meet training and qualification requirements, and reporting deficiencies to their Supervisor and Project Manager.

• Use equipment that has been inspected, and use equipment only as intended. • Follow all safe work practices in this procedure, in the project SH&E documents, as required

by local, State, Provincial, and Federal regulations or standards, and as instructed by the Marine Safety Officer or Vessel Operator.

• Immediately report incidents, near misses, unsafe acts and conditions when they occur to the Marine Safety Officer and/or the responsible supervisor.

4.2 Training and Qualifications

4.2.1 All personnel working aboard boats/vessels shall have completed training in accordance with S3NA-003-PR1 SH&E Training and maintain a current:

• Safe Boating Course (approved by Region SH&E Manager); • CPR/First Aid certification; • Hazardous Waste Operations and Emergency Reponses training (if marine operations involve

hazardous waste or the response to a hazardous waste emergency response); • Hepatitis A vaccination (if marine operations involve sampling sediments or surface waters

with contamination from sewage); • Fire extinguisher training (if a fire extinguisher is required on board); and • Additionally, all personnel shall be competent swimmers.

4.2.2 Vessel Operators shall have completed and maintain current:

• All training and qualification requirements noted above for all personnel working aboard boats/vessels.

• Field competency verification training or documented experience with operating the boat/vessel and that they understand all applicable marine safety regulations.

• Maintain current boat/captain licenses per local, state, provincial, and federal regulations and standards.

4.3 General Requirements

4.3.1 All boats and vessels shall be operated by a qualified Vessel Operator in accordance with local, State, Provincial, and Federal Marine Safety Laws.

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4.3.2 All tasks performed aboard a boat/vessel shall be assessed for hazards, and hazards shall be controlled, refer to S3NA-419-WI2 Boating Safe Work Practices. Assessment and controls shall be documented in the Task Hazard Analysis or Safety Plan, refer to S3NA-209-PR1 Hazard Assessment and Planning, S3NA-419-WI4 Float Plan and S3NA-419-WI6 Emergency Response Procedures.

4.3.3 Personal Protective Equipment shall be selected based on the task-specific hazard analysis, refer to S3NA-208-PR1 Personal Protective Equipment and S3NA-419-WI5 Marine Safety Equipment.

4.3.4 All boats and vessel will be outfitted with safety equipment as required by local, State, Provincial, and Federal regulations or standards, and as identified in the task-specific hazard analysis, refer to

4.3.5 Vessels working offshore shall be sized to withstand and remain stable through all forms of expected weather conditions, refer to S3NA-419-WI3 Small Boat Operation and S3NA-419-WI7 Hazardous Weather Operations. Local weather, tide, current conditions, and navigational needs shall be evaluated as a part of project planning.

4.3.6 All boats/vessels equipped with propulsion machinery shall be licensed and registered in accordance with local, State, Provincial, and Federal regulations or standards.

4.3.7 Should the vessel have locations designated as confined spaces, they shall be managed in accordance with S3NA-301-PR1 Confined Spaces.

4.3.8 Chartered or subcontracted boats/vessel or operators shall be evaluated by the Project Manager for overall suitability for the intended task. Charters/subcontractors are responsible for providing qualified operators and licensed and inspected boats/vessels and for stocking and maintaining emergency supplies and equipment, refer to S3NA-419-WI8 Charters and Subcontractors.

4.3.9 Impacts to marine traffic shall be evaluated as a part of project planning. Notification of the Coast Guard or other jurisdictional agency shall be made, as required by local, State, Provincial, and Federal regulations and standards. Additional notifications to other vessels via day shapes may be necessary.

4.3.10 Work in security zones and security sensitive areas (near bridges, reservoirs, etc.) shall be performed only with the authorization of governing security agency(s).

4.3.11 A daily safety inspection will be conducted by the Marine Safety Officer prior to beginning marine operations. The inspection criteria shall be developed as a part of project SH&E documentation.

4.3.12 A daily safety briefing of all field staff and operators shall be conducted by the Marine Safety Officer prior to beginning marine operations. The daily safety briefing shall include, at a minimum:

• Review of planned activities, including the associated Task Hazard Analysis; • Review of emergency procedures, including the location and operation of emergency supplies; • Discussion of personal protective equipment required for planned actives; and • Opportunity for field staff to ask questions.

5.0 Records 5.1 Float plans and other documents with planning and response will be retained in the project files.

6.0 Attachments 6.1 S3NA-419-WI1 Nautical Terminology

6.2 S3NA-419-WI2 Boating Safe Work Practices

6.3 S3NA-419-WI3 Small Boat Operation

6.4 S3NA-419-WI4 Float Plan

6.5 S3NA-419-WI5 Marine Safety Equipment

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6.6 S3NA-419-WI6 Emergency Response Procedures

6.7 S3NA-419-WI7 Hazardous Weather Operations

6.8 S3NA-419-WI8 Charters and Subcontractors

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Americas

Nautical Terminology S3NA-419-WI1

1.0 Nautical Terminology • Abeam – At right angles to the keel of the boat, but not on the boat.

• Aboard – On or within the boat.

• Above Deck – On the deck (not over it – see Aloft).

• Aft – Toward the stern of the boat.

• Aground – Touching or fast to the bottom.

• Ahead – In a forward direction.

• Aloft – Above the upper deck of the boat.

• Amidships – In or toward the center of the boat.

• Anchor – A heavy metal device, fastened to a chain or line, to hold a vessel in position, partly because of its weight but chiefly because the designed shape digs into the bottom.

• Astern – In back of the boat, opposite of ahead.

• Bearing – The direction of an object expressed either as a true bearing as shown on the chart, or as a bearing relative to the heading of the boat.

• Bight – Any curved section, slack part, or loop formed in a rope or line.

• Boat – A vessel for transport by water. Constructed to provide buoyancy by excluding water and shaped to give stability and permit propulsion.

• Bow – The forward end of the boat.

• Bulkhead – Wall-like constructions inside a vessel, as for forming watertight compartments, subdividing space, or strengthening the structure.

• Buoy – An anchored float used for marking a position on the water, a hazard, or a shoal. A surface marker floats for a mooring.

• Captain – A person who is at the head of or in authority of all others aboard a vessel.

• Certified Vessel (or Inspected Vessel) – A category of vessel that is subject to a mandatory U.S. Coast Guard safety inspection.

• Cleat – A fitting to which lines are made fast. The classic cleat to which lines are belayed is approximately anvil-shaped.

• Cockpit – A sunken, open area, generally in the after part of a small vessel, provides space for part or all of the crew.

• Dive – A descent into the water, an underwater diving activity utilizing compressed gas, an ascent, and return to the surface.

• Dock – A protected water area in which vessels are secured to a pier or a wharf.

• Drain Plug – A removable plug in the transom used for draining water out of a boat.

• Emergency Position Indicating Radio Beacon (EPIRB) – Transmits a signal that allows rescue personnel to determine a vessels position at sea once it is activated in the event of an emergency.

• Fathom – A depth increment of 6 feet (1.82 meters).

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• Fender – A cushion, placed between boats, or between a boat and a pier, to prevent damage.

• Float Plan – A document prepared by the boat crew and left with a competent person shore side that defines the itinerary and particulars of the vessel and crew, serving as an informational resource for emergency responders in the event the boat does not return at the appointed time.

• Freeboard – The portion of the side of a hull that is above the water.

• Gunwales – The widened edge at the top of the side rail of the boat, where the edge is reinforced.

• Knot – A measure of speed equal to one nautical mile (6,076 feet) per hour or 1.16 miles per hour.

• Knot – A fastening made by interweaving rope to form a stopper, to enclose or bind an object, to form a loop or a noose, to tie a small rope to an object, or to tie the ends of two small ropes together.

• Leeward – The direction away from the wind.

• Life-line – A line secured along the deck to lay hold of in heavy weather.

• Listing – Leaning to one side due to the unequal distribution of weight.

• Mooring – An arrangement for securing a boat to a mooring buoy or a pier.

• Overboard – Over the side or out of the boat.

• Personal Flotation Device (PFD) – PFD is official terminology for life jacket. When properly used, the PFD will support a person in the water and keep their face and nose (airway) out of the water in either a conscious or unconscious condition.

• Port – The left side of the boat when looking forward (toward the bow).

• Running Lights – Navigation lights required to be shown on boats underway between sundown and sunup.

• SCUBA Diving – A diving mode independent of surface supply in which the diver uses an open circuit, self-contained underwater breathing apparatus.

• Starboard – The right side of the boat when looking forward (toward the bow).

• Station bill – The posted bill showing assigned stations for each crew member during maneuvers and emergency drills.

• Stem – The forward most part of the bow.

• Stern – The after part (back) of the boat.

• Transom – The aft face or back board of the boat.

• Wake – Moving waves, track, or path that a boat leaves behind when moving across the water.

• Wide berth – At a considerable distance.

• Windward – Toward the direction from which the wind is coming (a.k.a. weather side); the opposite of leeward.

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Americas

Boating Safe Work Practices S3NA-419-WI2

1.0 General 1.1 Verify experience or conduct field competency verification of all Boat/Vessel Operators for the boat/vessel

to which they are assigned prior to starting operations.

1.2 Boats/vessels operated offshore, in ports or harbors, in navigation channels, or in waterways handling commercial traffic require approval by the Project Manager and Region Safety, Health and Environment (SH&E) Manager.

1.3 Project Managers shall select a vessel of appropriate size and configuration for expected work and operating conditions.

1.4 Vessels larger than 18 feet in length and/or greater than 25 horsepower must be approved for use by the Project Manager and the Region SH&E Manager.

1.5 Project Managers shall select a Boat/Vessel-qualified Operator, Marine Safety Officer, and field staff for the operating conditions.

1.6 Vessel operations are limited to 12 hours (dock to dock) to minimize fatigue.

1.7 Single-handed boat/vessel operations are not permitted unless approved by the Project Manager and the Region SH&E Manager. Controls, such as a communication and/or rescue plan, shall be in place for all single-handed boat/vessel operations.

1.8 Field staff is not permitted to work on deck alone unless approved by the Project Manager and the Region SH&E Manager. Controls, such as a communication and/or rescue plan, shall be in place for all field staff working alone.

1.9 The buddy system is required for all tasks, unless approved by the Project Manager and the Region SH&E Manager. Controls, such as a communication and/or rescue plan, shall be in place for all field staff working alone.

1.10 Vessel operators shall observe speed limits, right-of-way, and other applicable boating restrictions and guidelines.

1.11 Only qualified and authorized field staff are permitted to operate hydraulic machinery (winches, A-frames, etc.) for the deployment and recovery of scientific gear or surveying equipment.

1.12 All personnel shall be advised of the inherent risks associated with marine operations, including exposure to weather, marine operations, and chemical, biological, and physical hazards.

1.13 Swimming is prohibited, unless it is being conducted by certified divers in the completion of their assigned task or to prevent a serious injury or loss of life in a person in water/person overboard emergency.

1.14 A float plan shall be filed prior to departure.

1.15 All gear, personnel effects, and deck equipment shall be properly stowed to prevent shifting and blocking of walking/working paths.

1.16 All field staff in small boats shall remain properly seated at all times while the boat is underway. Sitting on the gunwales is not permitted. Standing at the edge of open transoms whenever the boat is underway or preparing to maneuver is not permitted.

1.17 All field staff shall keep their hands, arms, legs, and body away from docks, pilings, and other stationary objects when the vessel approaches to prevent a crushing injury.

1.18 Running is prohibited on the deck of any vessel.

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1.19 All lines shall be stored to prevent tripping or entanglement. All field staff shall stay clear of lines, cables, or chains under tension.

1.20 Moving and carrying gear aboard a boat shall be conducted with one free hand to hold onto railings whenever using stairwells. Heavy and bulky items shall be broken down into smaller lifts or lifted with assistance from another field staff member.

1.21 When loading boats/vessels with gear or people, distribute weight evenly to prevent listing.

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Americas

Small Boat Operations S3NA-419-WI3

1.0 Starting the Engine 1.1 The transport lock for the engine should be lifted or adjusted and the engine should be lowered into the

water. If starting in a shallow area, make sure that the engine is at least lowered to the point where the cooling water intake is below the waterline

1.2 Attach engine electronics to battery leads.

1.3 Check to make sure the fuel line is properly attached. Prime the fuel line by squeezing the fuel “bulb” until it becomes firm. Open the air vent on the top of the gas can cap.

1.4 Make sure throttle position is in neutral and if necessary turn choke on.

1.5 Turn the key or pull the start recoil-to-start engine. Inspect engine to make sure that cooling water system is working (i.e. a stream of water is flowing from the engine). If the cooling water system is not working, stop the engine immediately and check to make sure water intake and exit ports are clear.

1.6 Allow engine to warm up at idle speed before leaving dock or shore.

2.0 Leaving Dock or Shore 2.1 Make sure all personnel on board are wearing life jackets.

2.2 Loosen bow and stern lines, having one line tender hold a single wrap around a cleat to hold fast until the operator has given the command to release lines.

2.3 Prior to leaving shore or dock, the boat operator will make one final observation to determine if there are any oncoming boats or other hazards.

2.4 If the waterway is clear to proceed, the boat operator will instruct the line tender to release the lines and push away from the dock.

2.5 With all personnel seated and in position, and all docking lines and boat fenders recovered, the boat operator may put the engine in gear and make headway.

3.0 Returning to Dock or Shore 3.1 Before approaching dock or shore, determine which personnel will be in charge of bow and stern lines.

Notify line tenders not to “pull” the boat in by the line while docking; this may cause the operator to lose control of the boat.

3.2 Approach the dock or shore at low speed heading into any prevailing currents. Place the throttle in neutral position when arriving at dock. If the boat is still moving forward when at the dock, apply a quick burst of reverse throttle to stop the forward motion of the boat, recognizing that it may take several feet of travel to cease forward motion.

3.3 If necessary, secure fenders to the side of the boat next to the dock prior to landing

3.4 When the boat has stopped its forward motion and is sitting alongside the dock, have the bow and stern personnel step off the boat to secure the lines. Jumping any open water gap between the boat and dock is strongly discouraged; falling into the water between the boat and dock can cause serious injury. Once the lines have been secured, the engine can be secured.

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4.0 Anchoring 4.1 If short-term vessel anchoring is a required part of project operations, select an area offering maximum

shelter from wind, current, and boat traffic.

4.2 Determine depth of water and type of bottom (preferably sand or mud). Calculate the amount of anchor line you will need. General rule: the required length of anchor line is 5 to 7 times the depth of water plus the distance from the water to where the anchor will attach to the bow. For example, if the water depth is 8 feet (2.43 meters) and it is 2 feet (0.6 meters) from the top of water to your bow cleat, you would multiply 10 feet (3 meters) by a factor of 5 to 7 to get the amount of anchor line to put out. In tidal areas, be aware that the scope may need to be adjusted with tidal changes and boat swing.

4.3 Bring the bow of the vessel into the wind or current. When you get to the spot where you want to anchor, place the engine in neutral. When the boat comes to a stop, slowly lower the anchor. Do not throw the anchor over, as it will tend to entangle the anchor in the anchor line.

4.4 When adequate anchor line has been let out, back down on the anchor with the engine in idle reverse to help set the anchor. Secure the anchor line to the bow cleat at the point where you want it to stop; make certain you take a couple wraps around the cleat prior to "cleating off.”

4.5 When the anchor is firmly set, use reference points (landmarks) in relation to the boat to make sure the boat is not drifting. Check these points frequently, especially in areas subject to tidal changes. If the holding ground is questionable, let out additional anchor line, "cleat off,' and then back down on the anchor to get a good "bite" into the bottom.

5.0 Proper Fuel Management 5.1 To ensure that you will have enough fuel to safely return to the dock, always apply the one-third rule for fuel

management, which proportions your available fuel supply as follows:

5.1.1 One-third of fuel going out;

5.1.2 One third of fuel to get back; and

5.1.3 One third of fuel for reserve.

6.0 Small Boat Trailering 6.1 All boats/watercraft will be transported in accordance with Federal, State, Provincial, and local regulations.

Appropriate equipment (racks or trailers) will be used to transport boats/watercraft to the project site. Always launch from trailers at a designated boat ramp.

6.2 Prior to moving vehicle to boat ramp:

• Attach bow and stern lines to boat. Make sure length of lines are such that the lines reach the dock or shore where the boat will be placed.

• Remove the belly strap holding the boat to the trailer.

• Determine one individual who will assist the driver in backing the boat down the ramp. Work out audible and visual signals to assist driver in the off-loading process.

• Check to make sure drain plug is inserted in the boat.

• Disconnect trailer signal light cable.

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7.0 At the Boat Ramp 7.1 Before backing vehicle and trailer down the boat ramp, make sure the trailer and vehicle are in a straight line

7.2 Check to make sure that boat ramp is clear of personnel, vehicles, or boats before proceeding. The individual assisting the driver in backing up should stand to the driver's side of vehicle and well clear of trailer and either be positioned where the driver can make direct visual contact or see them in a mirror.

7.3 Back the trailer down the boat ramp to the edge of the water, and stop. The driver's assistant should disconnect the safety chain and cable from the boat and roll up any excess cable onto the trailer winch. (Disconnect the safety chain and cable ONLY if located on a LEVEL surface; otherwise, leave the cable and safely chain attached until the boat is floated off the trailer). The driver's assistant should take bow and stern lines in hand and then move clear of the trailer and vehicle.

7.4 Once all personnel are clear of vehicle, back the trailer into the water until the wheels are covered or the boat begins to float on its own. The backing momentum will push the boat away from the trailer. Once the boat is clear of the trailer, the trailer can be pulled out of the water. The boat should be pulled to the dock or shore and secured using bow and stern lines.

8.0 Loading the Trailer 8.1 Determine job assignments for personnel, one person will have to pilot the boat onto the trailer, one shore

person will have to attach the safety cable and reel the winch, and one person will have to drive the vehicle.

8.2 Back the vehicle and trailer down the boat ramp, stopping when the tires of the trailer are submerged, or when all but the two rollers nearest the vehicle are submerged. (Apply the emergency or parking brake on the vehicle).

8.3 Maneuver the boat away from the dock and approach the trailer at a very slow speed. The boat operator should aim the bow of the boat for the bow roller. Place the control of the boat in neutral just before arriving at the trailer. The shore person should stand clear as the vessel approaches and rides up the trailer.

8.4 When the boat comes to a complete stop, the shore person steps in, attaches the safety cable to the boat, and begins to reel in the cable. As the boat is being reeled in, care should be taken to keep the boat in line with the trailer.

8.5 Once the bow of the boat is snug with the bow roller, the boat operator should raise the engine and lock it for transport. The boat operator can then climb out of the boat. Care should be taken when climbing out of the boat. Using a step ladder to facilitate exiting the boat is recommended.

8.6 Once all personnel are clear of the boat and trailer, the vehicle driver should place the vehicle in drive and slowly begin to apply the accelerator. As this is being done, the driver should release the emergency brake and pull the trailer from the water. Make sure the boat is resting on all of the trailer rollers in an even manner. If this is not the case, then back the trailer into the water, loosen the safety cable and reposition the boat.

8.7 Once the trailer is completely out of the water, stop the vehicle on a level surface. A staging area is typically provided to complete final preparations for securing the boat and equipment prior to getting on the road.

9.0 Prior to Hauling the Boat 9.1 Remove all loose equipment from boat such as personal flotation devices, personal effects, sensitive survey

instrumentation, or other marine electronics. Remove all trash or flyaway items.

9.2 Secure compartment hatches, and stow and lash down anchors and other loose gear.

9.3 Remove the drain plug.

9.4 Attach the belly strap to firmly secure the boat to the trailer.

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9.5 Connect the trailer electrical connection to vehicle electrical plug. Check the turn signals, brake lights, and running lights on the trailer to make sure they are all working properly.

9.6 Return the boat/watercraft to the appropriate facility.

10.0 Special Considerations for Transporting a Boat 10.1 For car top transportation of canoes and kayaks, be sure the rack system is appropriately sized and

configured to secure the boat and that the vehicle is properly rated to handle the increased weight. Ratcheting or grip lock fasteners should be used to properly secure the boat and prevent shifting. A minimum of two belly straps plus additional lines both fore and aft are recommended.

10.2 For transporting small Jon-boats in the bed of a pick-up truck, ratcheting straps or grip lock fasteners are to be used to pull and hold the boat in the truck bed. One belly strap at the front end of the truck bed is also recommended to hold the boat down.

10.3 In either scenario, loads that project more than 3 feet beyond the rear bumper of the vehicle are required to fly a red warning flag from the back of the boat to warn motorists of the overhanging load.

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Americas

Float Plan S3NA-419-WI4

1.0 Float Plan 1.1 Float plans shall be prepared for all vessel operations to document vessel information (make/model, hull

color, and other distinguishing features), personnel on board, description of activities being performed, expected time of departure, planned time and location for arrival, course being traveled, and pertinent contact calling information for reaching the vessel. This information shall be submitted to a competent individual on shore who assumes the responsibility of initiating emergency response procedures if the vessel does not check in at the designated time.

1.2 In the event that a vessel’s return is delayed, and it is not an emergency, the boat crew must inform those holding the float plan and subsequently notify them upon returning to the dock so that the float plan can be closed out, avoiding an unnecessary and costly search.

1.3 If the vessel was trailered to a public ramp, then vehicle information (make/model and license), ramp location, and contact information for the local police department should be included in the float plan.

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2.0 Sample Float Plan

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Marine Safety Equipment (S3NA-419-WI5) Revision 0 December 31, 2014 PRINTED COPIES ARE UNCONTROLLED. CONTROLLED COPY IS AVAILABLE ON COMPANY INTRANET. 1 of 1

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Marine Safety Equipment S3NA-419-WI5

1.0 Requirements 1.1 All boats and vessel will be outfitted with marine safety equipment as required by local, State, Provincial,

and Federal regulations and standards, and as identified in the task-specific hazard analysis.

1.2 This includes, but is not limited to:

• U.S. Coast Guard-approved personal floatation device for each person aboard the boat/vessel;

• Sufficient lines for securing boat/vessel dockside;

• A sound-signalling device or appliance;

• Emergency engine shut-off lanyard, securely attached to boat/vessel operator;

• Lifeboats/rafts (offshore vessels);

• Fire/smoke detection equipment;

• Marine fire extinguishers;

• VHF Marine Radio;

• Emergency Position Radio Beacon;

• Life Ring/Retrieval Line;

• Survival Suits - For cold water conditions (water temperature less than 55 degrees Fahrenheit [12.8 edgrees Celsius]), a Coast Guard-approved Mustang suit shall be worn to protect personnel from risks of cold water immersion;

• Functioning, battery-operated spot or flashlights;

• Paddles or manual propelling devices;

• A bailing container;

• Buoyant heaving line no less than 49 feet 3 inch (15 meters) in length;

• Maps or appropriate navigation equipment; and

• First aid kit.

1.3 Safety equipment selected shall be in accordance with local, State, Provincial, and Federal regulations and standards.

1.4 Safety equipment shall be appropriate for the configuration and crew size as well as the size of the vessel.

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Emergency Response Procedures (S3NA-419-WI6) Revision 1 December 31, 2014 PRINTED COPIES ARE UNCONTROLLED. CONTROLLED COPY IS AVAILABLE ON COMPANY INTRANET. 1 of 3

Americas

Emergency Response Procedures S3NA-419-WI6

1.0 Requirements 1.1 Specific emergency response procedures shall be developed in the project-specific health and safety plan.

1.2 Review emergency procedures prior to departure to ensure that all hands understand their individual roles and responsibilities in the event of an emergency, and the location and proper use of emergency equipment aboard.

1.3 The following summary information is provided for consideration in the development of project-specific emergency response plans.

1.4 Emergency response plans may vary depending on the size and configurations of boats/vessels and the size and abilities of the crew.

2.0 Person Overboard 2.1 A person in the water shall be considered a person in distress, and immediate emergency response actions

shall be taken.

2.2 Prior to the start of operations, the Marine Safety Officer shall confirm that suitable rescue equipment is available to facilitate the emergency rescue of an individual who has fallen into the water.

2.3 The Marine Safety Officer shall conduct a safety briefing to discuss emergency response procedures, the type and location of safety gear that is available, and the roles and responsibilities of each crew members during an emergency.

2.4 All crew members should be instructed to

• NEVER LOSE SIGHT OF THE INDIVIDUAL IN THE WATER, • Inform the Captain, or vessel operator, as quickly as possible. • Throw a ring lifebuoy to the general vicinity of the victim. Do not throw a ring lifebuoy directly at the

victim. Hitting the victim with the ring buoy may cause additional injuries.

2.5 All person-overboard situations shall be reported as an incident in accordance with S3NA-004-PR1 Incident Reporting.

3.0 On-Board Fire 3.1 The Marine Safety Officer will conduct a safety orientation to inform crew members of the location of fire

extinguishers, specific emergency procedures, and the individual responsibilities expected of all hands in the event of an on-board fire.

3.2 If a fire is encountered, DO NOT attempt to fight the fire without sounding an alarm first; what could appear to be a small fire can quickly get out of control.

3.3 The extinguishers generally found on project vessels are portable hand-held units designed for multiple use applications, i.e., extinguishers labeled “BC” are approved for both B and C type fires. These types of extinguishers can be carried to the fire to quickly knock down the fire before it has the chance to get out of control. Crew members must be aware that, because these extinguishers are portable, they carry only a limited supply of extinguishing agent. In general, continuous application can be sustained for only a minute or less. Extinguishers are activated by pulling the safety pin and squeezing the release handle. Aim the extinguisher at the base of the flame. Apply the extinguishing agent in short bursts and in a sweeping motion across the base of the fire until the fire is extinguished. If you must enter a space, never let the fire get between you and the door. If your initial attack with a portable extinguisher fails get out immediately and close the door.

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4.0 Abandon Ship 4.1 The Marine Safety Officer will conduct a safety orientation prior to departure to point out the location of life

rafts, procedures for manually deploying the raft, and specific individual responsibilities expected of all hands in the event the vessel needs to be abandoned.

4.2 The decision to abandon ship is a matter of last resort; it is always better to remain with the boat, which is much more visible, until rescue assistance arrives on the scene. If the severities of the situation, through causes that include collision, sinking, fires, or grounding dictate that it is safer to abandon ship, then a distress call must be made to inform authorities of your situation so that rescue assistance can be provided and that your time in the water is kept to a minimum.

4.3 For coastal and offshore waters, a distress call is made on the marine VHF radio using Channel 16. This frequency is monitored by the U.S. Coast Guard and it is the official hailing frequency reserved for ship-to-ship calling and broadcasting safety information and distress calls. Appropriate actions for transmitting a distress signal will be taken by the ship’s crew, but if matters need to be taken into your own hands, the protocols of a distress call are:

4.4 A distress call protocol begins with “MAYDAY” “MAYDAY” “MAYDAY,” after which the following information is provided:

• Vessel name and description,

• A brief description of your emergency

• Your position and the last landmark seen,

• The number of people that are on board and/or in the water,

• What form of assistance is needed/advise of any imminent dangers,

• Your cell phone number if calling by cell, and

• If hailing on the marine VHF wait 10 seconds for a response. Repeat this information if there is no response.

4.5 For inland waters, or work within protected coastal waters where local authorities (marine patrol, harbormaster, police, and fire rescue) may provide a more effective response, dial 911 emergency services and provide the same information listed above. It is also important to remember that most powered vessels built after 1978 are designed to float even when full of water or in the capsized position. If either of these situations occurs, it is important that you stay with the boat if possible, and remain calm. To reduce the effects of hypothermia, climb into or onto the boat to get as much of your body as possible out of the water.

4.6 Vessels working offshore must carry sufficient numbers of U.S. Coast Guard-approved life rafts to accommodate 100 percent of the persons aboard. These units are designed to float free from the sinking vessel and to inflate automatically in the unlikely event that the vessel should sink. A hydrostatic release mechanism and weak link are provided on the life raft container to satisfy this requirement. The life raft container can also be removed from the storage cradle and deployed manually, if the situation provides sufficient time to safely achieve this task. An instruction card is generally displayed in a prominent location aboard the vessel and can also be found directly on the raft container. If the vessel is operating in ocean service or coastwise transit the life raft must be rated for Ocean Service.

4.7 The decision to abandon ship lies solely with the Captain of the vessel. If the order is ever given, you will be expected to follow the directions of the ships’ crew, in a calm and orderly fashion. DO NOT PANIC! You will be required to assemble at a predetermined station, fully clothed, with your lifejacket on. For offshore cold-water operations, bring your immersion suit. If time permits, don your immersion suit; the suit will protect you from the elements and provide plenty of flotation, but keep your lifejacket with you. Stand by calmly at your station and await further orders. Bring a portable radio unit and ensure that the ships’ Emergency Position Indicating Radio Beacon has been energized. If the order to abandon ship is given, enter the life rafts in an orderly fashion and remain in the general vicinity of the vessel until rescue assistance arrives.

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5.0 Emergency Position Indicating Radio Beacon (EPIRB) 5.1 The EPIRB is a battery-operated, self-activating emergency transmitter. All vessels operating more than 20

miles (32 kilometers) from land are required to carry at least one approved Class-A EPIRB.

5.2 An EPIRB unit is not generally required on vessels that are operating less than 20 miles (32 kilometers) from land and that are equipped with a marine VHF-FM radio. The EPIRB will enable rescuers to quickly locate a disabled vessel by providing a tracking signal to all search and rescue units within range of the unit.

5.3 Prior to departure, check with the Captain of the vessel to ensure that the unit is functioning properly and that the unit has been suitably tested within the last 30 days.

5.4 The operation of most units is usually tested simply by activating the TEST switch and checking for a positive indication from the unit. If no indication is observed, check or replace the battery, and retest. A defective unit should be returned to an authorized service center for repairs.

5.5 A functioning unit should be stowed in a suitable rack, in the inverted position, with the power switch in the automatic position. The unit will float free from the storage rack in the unlikely event the vessel sinks and begin transmitting automatically when it rights itself on the surface.

5.6 If the situation permits, the EPIRB should be brought into the life raft in the event that the vessel must be abandoned; the unit can be activated manually simply by inverting the unit to the upright position.

5.7 Do not test the EPIRB by inverting the unit, as this will send out a false alarm and initiate an unnecessary search and rescue for which you may be held accountable.

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Hazardous Weather Operations (S3NA-419-WI7) Revision 0 December 31, 2014 PRINTED COPIES ARE UNCONTROLLED. CONTROLLED COPY IS AVAILABLE ON COMPANY INTRANET. 1 of 2

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Hazardous Weather Operations S3NA-419-WI7

The following guidelines are provided as safety considerations to avert the risks of encountering hazardous weather and seas during on-water project operations.

1.0 Planning 1.1 Use online resources such as National Oceanic and Atmospheric Administration (NOAA) marine weather

forecasts to evaluate current and predicted weather and predicted sea-state information, and available National Data Buoy Center buoy information to cross-check marine forecasts with real-time and hind cast records of offshore sea-state conditions.

1.2 Additional protective measures could include assigning a coworker at the office to watch developing weather reports and radar loops to track incoming weather if there is some uncertainty in the weather at the time of departure.

1.3 On-water operations should be postponed whenever small craft warnings are in effect.

1.4 Despite the best of planning measures, severe weather such as thunderstorms, squall lines, gusty winds, and shifting wind directions with approaching storms or weather fronts can develop quickly and present a safety risk to marine personnel. Therefore, it is important that proper consideration be given to the vessel being selected to support your project and the operational limitations associated with that vessel. The vessel must be sized and configured to weather the worst case sea-state that might be expected in a given day. Factors such as length, freeboard, horsepower, sea-keeping abilities, watertight integrity of enclosed spaces, and inherent flotation should be considered in selecting a vessel for working in exposed waters, either offshore or a windward side of large bodies of water whether in coastal or inland locations.

1.5 While offshore, monitor NOAA weather radio for the latest watches, warnings, or advisories. If weather conditions are predicted to deteriorate, be sure to leave for the return trip back to dock with ample time to avoid hazardous weather conditions.

1.6 If possible, consider revising your project itinerary to reposition the vessel to work within a survey area or group of sampling stations that are closer to shore if weather conditions appear threatening or if wind directions have winds coming off the land and thus near-shore sea-states would be reduced due to the reduced fetch, saving the furthest offshore or most exposed survey areas for better weather.

2.0 Sudden Weather Changes 2.1 Dark, threatening clouds usually foretell the approach of severe weather. Other things to watch for are a

sudden drop in air temperature, a shift in wind direction, an increase in winds speeds, or an increase in winds that are running counter to the prevailing current direction—a situation that can quickly increase sea states.

2.2 If thunder can be heard, you are at risk of being struck by lightning. Open-vessel platforms (those without adequate enclosed spaces for shelter) shall return to the dock immediately so that personnel can seek refuge. If there is insufficient time to get back to the dock, seek out the nearest shelter (shore side support truck, alternate dockage, or any nearby building along shoreline). As a last resort, personnel should set out an anchor and get as low as possible in the boat. Use boat cushions or other non-conducting materials to insulate the body from metal hulls. For vessels with enclosed spaces, keep below decks (if possible) keeping away from metal objects that are not grounded, and do not touch more than one grounded object at the same time.

2.3 If you find yourself in a rapidly deteriorating sea while in route back to the dock:

2.3.1 Reduce vessel speed enough to maintain control, while still maintaining headway.

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Hazardous Weather Operations (S3NA-419-WI7) Revision 0 December 31, 2014 PRINTED COPIES ARE UNCONTROLLED. CONTROLLED COPY IS AVAILABLE ON COMPANY INTRANET. 2 of 2

2.3.2 Turn on running lights.

2.3.3 Sound fog horn or audible device if there is fog.

2.3.4 Head the bow of the boat at about a 45-degree heading to the wave direction.

2.3.5 Keep bilges free of accumulating water.

2.3.6 Check that gear is secured.

2.3.7 Remain calm and think clearly.

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Charters and Subcontractors (S3NA-419-WI8) Revision 0 December 31, 2014 PRINTED COPIES ARE UNCONTROLLED. CONTROLLED COPY IS AVAILABLE ON COMPANY INTRANET. 1 of 1

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Charters and Subcontractors S3NA-419-WI8

1.0 Responsibilities 1.1 When chartering or subcontracting uninspected vessels, the Project Manager shall determine the overall

suitability of the vessel for the expected task.

1.2 Subcontractors are responsible for:

1.2.1 Providing qualified or U.S. Coast Guard-licensed marine staff, the appropriately sized vessel, and all required gear to safely support field activities.

1.2.2 Stowing and maintaining all safety and emergency equipment.

1.2.3 Being service-ready at the start of all operations. All unsafe gear will be removed from service until unsafe conditions have been corrected.

1.2.4 Maintaining current U.S. Coast Guard inspections of the following items:

• Hull inspection to ensure seaworthiness of vessel; • Main/auxiliary power inspection to ensure safe and operable machinery for vessel propulsion

and emergency power; • Pressure vessel inspection to ensure that they are structurally sound with operable safety

devices; • Electrical systems inspection to ensure satisfactory installation of wiring and equipment; • Lifesaving systems inspection to ensure satisfactory and adequate means to abandon ship; • Fire-fighting systems inspection to ensure fixed and portable devices are suitable for the

intended space and type of fire; • Navigation inspection to ensure adequacy and proper operation of navigation equipment; • Pollution prevention inspection to ensure compliance with international regulations and

domestic laws; and • The vessel should hold some form of “letter of designation” that it can legally operate, at a

minimum, as a six-passenger charter, and within this designation the vessel must be operated by a properly licensed Captain and competent crew.

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Y:\Reports\Neodesha\SSWI_WP\SSWI Final\Sediment and

Surface Water Investigation Work Plan 20160229.docx

Tables

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Table 1Analytical Parameters

Analyte Group

Constituents and Analytical Method Method

Reporting Limitfor Sediment

Samples(ug/kg)

Reporting Limitfor Surface

Water Samplesug/L

Benzene 8260B 5 1 Toluene 8260B 5 1 Ethylbenzene 8260B 5 1 Xylenes (total) 8260B 5 3 1,1,1-Trichloroethane 8260B 5 1 1,1,2,2-Tetrachloroethane 8260B 5 1 1,1-Dichloroethane 8260B 5 1 1,1-Dichloroethene 8260B 5 1 1,2-Dibromoethane 8260B 5 1 1,2-Dichloroethane 8260B 5 1 1,2-Dichloroethene (total) 8260B 5 1 1,2-Dichloropropane 8260B 5 1 1,2,4-Trimethylbenzene 8260B 5 1 1,3,5-Trimethylbenzene 8260B 5 1 1,4-Dioxane 8260B 500 100 2-Hexanone 8260B 20 10 4-Isopropyltoluene 8260B 5 1 Acetone 8260B 20 10 Acrylonitrile 8260B 100 20 Benzene 8260B 5 1 Bromodichloromethane 8260B 5 1 Carbon disulfide 8260B 5 5 Chlorobenzene 8260B 5 1 Chloroethane 8260B 10 1 Chloroform 8260B 10 1 Chloromethane 8260B 10 1 Dibromochloromethane 8260B 5 1 Dibromomethane 8260B 5 1 Ethanol 8260B/8015 500 5000 Ethylbenzene 8260B 5 1 Ethylene dibromide (EDB) 8260B 5 1 Isopropanol 8260B TIC tic Isopropylbenzene 8260B 5 1 Methyl ethyl ketone; MEK; 2-Butanone 8260B 20 10 4-Methyl-2-pentanone 8260B 20 10 Methylene chloride 8260B 5 1 Methyl-tertiary-butyl-ether; MTBE 8260B 20 1 n-Butylbenzene 8260B 5 1 n-Propylbenzene 8260B 5 1 sec-Butylbenzene 8260B 5 1 Styrene 8260B 5 1 Tetrachloroethene 8260B 5 1 Toluene 8260B 5 1 trans-1,4-Dichloro-2-butene 8260B 5 20 Trichloroethene 8260B 5 1 Trichlorofluoromethane 8260B 10 1 Vinyl acetate 8260B 10 20 Vinyl chloride 8260B 10 1 Xylenes (total) 8260B 5 3

BTEX

Solvents

Page 1 of 3 February 2016

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Table 1Analytical Parameters

Analyte Group

Constituents and Analytical Method Method

Reporting Limitfor Sediment

Samples(ug/kg)

Reporting Limitfor Surface

Water Samplesug/L

methyl tert -butyl ether (MTBE) 8260B 5 1 ethyl tert -butyl ether (ETBE) 8260B 5 1 tert-amyl methyl ether (TAME) 8260B 5 1 diisopropyl ether (DIPE) 8260B 5 1 tert-butyl alcohol (TBA) 8260B 25 10 Bis(2-ethylhexyl) phthalate 8270 330 10 o-Cresol 8270 330 10 m-Cresol 8270 330 10 p-Cresol 8270 330 10 Di-n-butyl phthalate 8270 330 10 1,2-Dichlorobenzene 8270 330 10 1,3-Dichlorobenzene 8270 330 10 1,4-Dichlorobenzene 8270 330 10 Diethyl phthalate 8270 660 10 2,4 Dimethylphenol 8270 330 10 Dimethyl phthalate 8270 330 10 2,4 Dinitrophenol 8270 1600 50 4-Nitrophenol 8270 1600 50 Phenol 8270 330 10 Pyridine 8270 660 10 Quinoline 8270 1600 10 1-Methylnaphthalene 8270SIM 10 10 2-Methylnaphthalene 8270SIM 10 10 Acenaphthene 8270SIM 10 10 Acenaphthylene 8270SIM 10 10 Anthracene 8270SIM 10 10 Benzo(a)anthracene 8270SIM 10 10 Benzo(a)pyrene 8270SIM 10 10 Benzo(b)fluoranthene 8270SIM 10 10 Benzo(g,h,i)perylene 8270SIM 10 10 Benzo(k)fluoranthene 8270SIM 10 10 Chrysene 8270SIM 10 10 Dibenz(a,h)anthracene 8270SIM 10 10 Fluoranthene 8270SIM 10 10 Fluorene 8270SIM 10 10 Indeno(1,2,3-cd)pyrene 8270SIM 10 10 Naphthalene 8270SIM 10 10 Phenanthrene 8270SIM 10 10 Pyrene 8270SIM 10 10

Antimony 6010 1000 10 Arsenic 6010 1000 10 Barium 6010 1000 10 Beryllium 6010 100 1 Cadmium 6010 500 5 Chromium (Total) 6010 1000 5 Cobalt 6010 500 5 Lead 6010 300 5 Mercury (method 7471A/7470A) 6010 33 0.2 Nickel 6010 500 5 Selenium 6010 500 15 Silver 6010 1000 7 Vanadium 6010 1000 10 Zinc 6010 10,000 50

Metals (6010B/6020)

Inorganics

Semivolatile Organics

Polyaromatic Hydrocarbons (PAHs)

Oxygenates

Page 2 of 3 February 2016

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Table 1Analytical Parameters

Analyte Group

Constituents and Analytical Method Method

Reporting Limitfor Sediment

Samples(ug/kg)

Reporting Limitfor Surface

Water Samplesug/L

General Chemistry pH 150.1 0.1 0.1 TPH (as Diesel) OA2 16 mg/kg 0.4 TPH (as Fuel oil no.6) OA2 110 mg/kg NA TPH (as Gasoline) OA1 0.025 mg/kg 0.4 TPH (as Jet fuels) OA2 16 mg/kg 0.4 TPH (as Kerosene) OA2 16 mg/kg 0.4 TPH (as Miscellaneous) OA2 16 mg/kg 0.4 TPH (as Naphtha) OA2 16 mg/kg NA

Notes:1. ug/kg = micrograms per kilogram2. TIC - Tentatively Identified Compound

Total Petroleum Hydrocarbons (TPH)

Page 3 of 3 February 2016

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Table 2Proposed Sediment and Surface Water Sampling Locations

Location ID Area

Corresponding Existing Station Rationale Comments

UP1 Upstream Fall/Up Upstream reference/control At Huser BridgeUP2 Upstream -- Upstream reference/controlUP3 Upstream -- Upstream reference/controlUP4 Upstream -- Upstream reference/controlUP5 Upstream Fall/Park Upstream reference/control At Public Park

SITE1 Potential Discharge area -- Evaluate discharges from ditch from former Oil Separator Pond Mouth of ditch

SITE2 Potential Discharge area -- Evaluate conditions in Fall River immediately downstream of ditch outfall Downstream of ditch

SITE3 Potential Discharge area Fall/Intake Evaluate conditions in Fall River at Neodesha water intake At water intake

SITE4 Potential Discharge area -- Evaluate conditions in Fall River adjacent to potential contaminated groundwater plume discharge area

Near bank area closest to plume

SEPARATOR POND Potential Discharge area -- Evaluate conditions of discharge area and evaluate potential contributions from from former Oil Separator Pond. Upstream of ditch

DOWN1 Downstream Fall/75 Evaluate conditions downstream of potential discharge area At Highway 75 Bridge

DOWN2 Downstream -- Evaluate conditions downstream of potential discharge area In basin behind dam/diversion structure

DOWN3 Downstream -- Evaluate conditions downstream of potential discharge area

DOWN4 Downstream -- Evaluate conditions downstream of potential discharge area

DOWN5 Downstream --Evaluate conditions downstream of potential discharge area and evaluate potential contributions from storm water ditch

associated with former Settling Ponds.Downstream of outfall

VERDIGRIS/UP Upstream VERDIGRIS/UP Evaluate baseline conditions should River ever become impacted. Downstream of outfall

VERDIGRIS/75 Downstream VERDIGRIS/75Evaluate conditions downstream of potential discharge area and evaluate potential contributions from storm water ditch

associated with former Settling Ponds.At Highway 75 Bridge

M:\NEO\CAS\SurfWaterSediment WP\Table 3 Page 1 of 1 August 2008

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Surface Water Investigation Work Plan 20160229.docx

Figures

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About AECOM AECOM (NYSE: ACM) is a global provider of professional technical and management support services to a broad range of markets, including transportation, facilities, environmental, energy, water and government. With approximately 45,000 employees around the world, AECOM is a leader in all of the key markets that it serves. AECOM provides a blend of global reach, local knowledge, innovation, and collaborative technical excellence in delivering solutions that enhance and sustain the world’s built, natural, and social environments. A Fortune 500 company, AECOM serves clients in more than 130 countries and has annual revenue in excess of $8.0 billion. More information on AECOM and its services can be found at www.aecom.com.

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